SAR

When filing a 90 day followup SAR do you report the date of activity as being the first date of the suspicious activity or do you use the dates of the suspicious activity as being within the actually 90 day? I have read the answer to this question before, but I am having a hard time locating it now. Also do you report the amount of the SAR for a 90 day followup as the total amount during the entire time of the suspicious activity or just the amount during the 90 day period?

Time period is from first day of initial SAR to last day of current SAR. Aggregate amounts over entire period.

Brenda, is there FinCEN guidance on that?

Check out this excerpt from FinCEN's SAR Activity Review:

http://www.bankersonline.com/security/sar/sarongoing.html

You'll find the complete FinCEN article on page 43 of Issue 4 of SAR Activity Review: Trends, Tips and Issues, at http://www.fincen.gov/sarreview082002.pdf

Thank you John.